Security rights in movable property in European private law
著者
書誌事項
Security rights in movable property in European private law
（The common core of European private law / general editors, Mauro Bussani, Ugo Mattei）
Cambridge University Press, 2004
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注記
Includes bibliographical references and indexes
内容説明・目次
内容説明
For every transnational lawyer, it is vital to know the differences between national secured transactions laws. Since the applicable law is determined by the place where the collateral is situated, it may change when movables are brought from one state to another. Introductory essays from comparative lawyers set the scene. The book then presents a survey of the law relating to secured transactions in the member states of the European Union. Following the Common Core approach, the national reports are centred around fifteen hypothetical cases dealing with the most important issues of secured transactions law, such as the creation of security rights in different business situations, the relationship between debtor and secured creditor, the nature of the creditor's rights and their enforcement as against third parties. each case is followed by a comparative summary. A general report evaluates the possibilities of European harmonisation in the field of secured transactions law.
目次
- Part I. Introduction and context: 1. Introduction Eva-maria Kieninger
- 2. A labyrinth of creditors Willem J. Zwalve
- 3. Security in movables in the United States Harry C. Sigman
- 4. The English law of security Michael Bridge
- 5. The European Bank for Reconstruction and Development's Secured Transactions project Frederique Dahan and John Simpson
- Part II. The Case Studies
- Evaluation: a common core? Convergences, subsisting differences and possible ways for harmonisations Eva-maria Kieninger
- Indexes.
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